Legal

PAIA Manual

Prepared in terms of Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 (as amended). Last updated: 31 March 2026.

1. Introduction

This manual is published in terms of Section 51 of the Promotion of Access to Information Act, No. 2 of 2000 ("PAIA"), read together with Sections 17 and 55 of the Protection of Personal Information Act, No. 4 of 2013 ("POPIA").

The purpose of this manual is to provide information to the public on how to submit a request for access to records held by the organisation, as well as to describe the categories of records held and personal information processed.

2. Key contact details

Registered nameAlgojungle (Pty) Ltd
Trading asMetaPOS
Registration number2019/608881/07
Registered address416 Montebello, 4 Montrose Street, Newlands, Cape Town 7700
Postal address416 Montebello, 4 Montrose Street, Newlands, Cape Town 7700
Head of private body / Information OfficerJason Naicker, Founder & Managing Director
Telephone+27 72 593 8957
Emailinfo@metapos.co.za
Websitemetapos.co.za

3. Guide on how to use PAIA

The Information Regulator has published a guide in terms of Section 10 of PAIA, which describes how to exercise rights conferred by PAIA. This guide is available from the Information Regulator's website at inforegulator.org.za/paia.

The guide is also available for inspection, free of charge, at our registered address during normal business hours.

4. Records available without a request for access

The following records are publicly available on the MetaPOS website or upon reasonable request, without the need to submit a formal PAIA request:

This PAIA manual. The MetaPOS cookie policy (available at metapos.co.za/cookie-policy.html). General information about the company, its services, and its leadership team (available at metapos.co.za).

5. Records available in accordance with other legislation

Records are kept in accordance with, among others, the following legislation. This list is not exhaustive and is provided for reference:

Companies Act, No. 71 of 2008. Basic Conditions of Employment Act, No. 75 of 1997. Income Tax Act, No. 58 of 1962. Value Added Tax Act, No. 89 of 1991. Electronic Communications and Transactions Act, No. 25 of 2002. Protection of Personal Information Act, No. 4 of 2013. Promotion of Access to Information Act, No. 2 of 2000.

6. Description of records held

The following is a description of the subjects on which MetaPOS holds records and the categories of records held under each subject. The availability of any record is subject to the grounds for refusal set out in PAIA.

6.1 Company and corporate records

Memorandum of Incorporation and company registration documents. Minutes of board meetings and shareholder resolutions. Investor agreements and shareholder records. B-BBEE documentation.

6.2 Financial records

Annual financial statements. Tax returns and SARS correspondence. Invoices (issued and received). Banking and payment records. Records held in the Xero accounting system.

6.3 Employment and contractor records

Employment contracts and service agreements. Remuneration records. Contractor and consultant agreements. Leave and attendance records.

6.4 Client and partner records

Consulting agreements and service level agreements. Heads of agreement and memoranda of understanding. Client contact details. Correspondence with clients and partners.

6.5 Product and operational records

Store owner registration data (names, contact details). Sales transaction data captured through the MetaPOS application. App integration agreements. Technical architecture and system documentation.

6.6 Marketing and intellectual property

Brand guidelines and marketing materials. Website content and analytics data. Domain name registrations. Trademarks and trade names.

7. Processing of personal information (POPIA)

In terms of Section 51(1)(c) of PAIA, as amended by POPIA, the following information is provided regarding the processing of personal information by MetaPOS.

7.1 Purpose of processing

MetaPOS processes personal information for the following purposes: to provide our mobile POS application and data platform services to store owners; to deliver data analytics and consulting services to clients; to manage employment and contractor relationships; to process financial transactions and comply with tax obligations; to operate and improve our website; and to comply with applicable laws and regulations.

7.2 Categories of data subjects

CategoryPersonal information collected
Store ownersName, contact details (phone number, email), store name and location, sales transaction data
Consulting clients and partnersContact person name, email address, phone number, job title, company name
Employees and contractorsName, contact details, identity number, banking details, tax reference number, employment records
Investors and board membersName, contact details, identity number, shareholding details
Website visitorsIP address, browser and device information, pages visited (only if analytics cookies are accepted)

7.3 Recipients of personal information

Personal information may be shared with the following categories of recipients where necessary for the purposes described above:

Google LLC (Google Workspace for business operations, Google Analytics for website usage, Google Cloud Platform for application infrastructure). Xero Limited (accounting and financial record-keeping). Xneelo (Pty) Ltd (website hosting). South African Revenue Service and other regulatory or governmental bodies where required by law. Professional advisors including legal counsel and auditors.

7.4 Cross-border transfers

Some of the third-party service providers listed above process personal information on servers located outside of South Africa, including in the United States, the European Union, and other jurisdictions. Where personal information is transferred outside of South Africa, MetaPOS ensures that appropriate safeguards are in place as required by Section 72 of POPIA, including that the recipient is subject to laws or binding agreements that provide an adequate level of protection substantially similar to the conditions of POPIA.

7.5 Security measures

MetaPOS takes reasonable technical and organisational measures to protect personal information against loss, damage, unauthorised access, or unlawful processing. These measures include access controls, encryption in transit, and secure cloud infrastructure.

7.6 Retention

Personal information is retained only for as long as necessary for the purposes for which it was collected, or as required by applicable law. Financial records are retained in accordance with the requirements of the Income Tax Act and the Companies Act. When personal information is no longer required, it is destroyed, deleted, or de-identified in a manner that prevents reconstruction.

8. Request for access to records

A request for access to a record held by MetaPOS must be made on the prescribed form (Form 2) as set out in the Regulations to PAIA. The form is available from the Information Regulator's website at inforegulator.org.za/paia.

The completed form must be submitted to the Information Officer at the contact details provided in Section 2 of this manual.

The requester must provide sufficient detail to enable the Information Officer to identify the record(s) requested, the form of access required, and the postal or email address of the requester. If the request is made on behalf of another person, proof of authorisation must be provided.

8.1 Fees

A request fee is payable before the request will be processed. An access fee may also be payable if the request is granted. The applicable fees are prescribed by regulation and are available from the Information Regulator. Payment of the request fee may be waived for personal requesters (persons requesting access to their own personal information).

8.2 Decision

The Information Officer will respond to a request within 30 days of receipt. This period may be extended by a further 30 days if the request is for a large number of records or requires a search through a large number of records, and complying within the original period would unreasonably interfere with the activities of the organisation.

If the request is refused, the requester will be informed of the reasons for the refusal and the remedies available, including the right to lodge a complaint with the Information Regulator.

9. Grounds for refusal of access

Access to records may be refused on the grounds set out in Chapter 4 of Part 3 of PAIA. These include, among others:

Protection of the privacy of a third party who is a natural person (Section 63). Protection of commercial information of a third party (Section 64). Protection of the commercial information of the private body (Section 68). Protection of research information (Section 69). Records that are privileged from production in legal proceedings (Section 67).

Each request will be assessed on its merits, and the Information Officer will apply the relevant provisions of PAIA in determining whether to grant or refuse access.

10. Remedies

If a requester is dissatisfied with the Information Officer's decision, the requester may lodge a complaint with the Information Regulator within 180 days of notification of the decision. The Information Regulator's contact details are:

NameInformation Regulator (South Africa)
AddressJD House, 27 Stiemens Street, Braamfontein, Johannesburg 2001
Telephone010 023 5207
Emailcomplaints.IR@justice.gov.za
Websiteinforegulator.org.za

11. Availability of this manual

This manual is available for inspection, free of charge, on the MetaPOS website at metapos.co.za/paia-manual.html and at the registered address of the company during normal business hours.

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